Traffic Jam platform

On this page

• Description
• Why a privacy impact assessment was completed
• Additional information
• Related personal information banks
• For more information about this privacy impact assessment

Description

Traffic Jam is an information discovery tool that uses site crawlers to collect data from advertisements for sexual services (sex ads) posted to publicly available adult service websites. Online sex ads are often only posted to adult service websites for a very short time - sometimes just minutes or hours - which is usually sufficient to generate significant interest from potential clients. The technique of removing these advertisements after short periods of time aids traffickers in avoiding police detection as they move their victims from location to location (town, city, country). Traffic Jam collects and retains information from these advertisements, resulting in minimal impact from the advertisement deletion strategy. The Royal Canadian Mounted Police (RCMP) uses this tool to aid in missing persons, child sexual exploitation and human trafficking investigations.

Why a privacy impact assessment was completed

The RCMP uses this tool to collect personal information in pursuit of lawful investigations, which are considered a decision-making process about an identifiable individual. As such, the RCMP recognizes that the use of this tool meets the requirements for a privacy impact assessment in accordance with s.C.2.2.9.1 of the Directive on Privacy Practices.

Additional information

During the PIA drafting process the following risks were identified and mitigated:

1. For accountability purposes and to ensure the tool is being used appropriately, the National Technology Onboarding Program provided each program area with a Directive on the use of Traffic Jam (the Directive), which provides direction on the use and limitations of the tool by RCMP end-users.
2. Security and safeguards were assessed through the security process and an Authority to Operate was issued by Departmental Security for the tool in January 2024.
3. To ensure accuracy of the personal information and minimal intrusiveness for individuals, the Facial Recognition Technology (FRT) capabilities of Traffic Jam were disabled.
4. In addition to algorithms embedded within Traffic Jam tool to limit the collection of information from sex workers engaged in lawful activities, the Directive includes specific limitations for RCMP end-users to further reduce this risk, and focus on victims of human trafficking and missing persons.

Outstanding risks that are anticipated to be mitigated in the coming months include:

1. To ensure accountability of proper use of the tool by RCMP employees the RCMP will request that auditing features of users’ search history are enabled by the company.
2. To ensure a proper governance structure within the RCMP, the licenses will be distributed by one unit, that will be determined upon completion of the pilot project of the tool.
3. The RCMP has not finalized an Algorithmic Impact Assessment for the tool, but is in the process of reviewing and completing this assessment.

Related personal information banks

All information collected through the use of this tool is described in RCMP PPU 005 - Operational Case Records.

For more information about this privacy impact assessment

Contact the RCMP's Privacy Management Division of the RCMP at atippolicy_politiqueaiprp@rcmp-grc.gc.ca.